2011-02-28_REVISION - C1981041

• Permit No: C1981041
• IBM Index Class Name: REVISION
• Doc Date: 2/28/2011
• Doc Name: Review Letter
• From: Brock Bowles
• To: Mike Boulay
• Type & Sequence: TR60
• Email Name: MPB
• Email Name: SB1
• Media Type: D
• Archive: No

STATE OF COLORADO
DIVISION OF RECLAMATION, MINING AND SAFETY
Department of Natural Resources 44.
1313 Sherman St., Room 215
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Denver, Colorado 80203 IV IS ' ON
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Phone: [phone] PLECLAMAT

[phone]
FAX:

SAFETY
Bill Ritter, Jr.
Governor
Date: February 28, 2011
Mike King
Executive Director
To: Mike Boulay
Loretta E. Pineda

F
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RE: Roadside Mine Permit No.C-1981-041
Technical Revision No. 60 (TR-60)
Pursuant to your request, I have reviewed the referenced TR-60 submitted by J. E. Stover and
Associates on behalf of Snowcap Coal Company (SCC). TR-60 is being submitted by SCC to address
the persistent invasion/dominance of cheatgrass on reclaimed land and corresponding reference areas
at the Roadside Mine, five miles northeast of Palisade, Colorado. Herbicide treatment and interseeding
were done in 2005-07 in an attempt to reduce the dominance of cheatgrass. Despite repeated attempts,
it appears at this time there is not sufficient technology to control the persistent invasion/dominance of
cheatgrass. TR-60 is proposing to change the cover, production, diversity standards and sampling
methods for the purposes of bond release in Tab 14 of the approved permit.
My comments about TR-60 are as follows:
1. Page A14-11-4, Species Diversity- SCC is requesting to add anew requirement to
compensate for the reduction in warm-season grass cover. The new requirement is "for the
presence of two different species in each life-form category." Please list the life-forms in
which two species will be required.
2. Page A14-11-4, Sampling Methodology - The text states that SCC "intends to implement
Cedar Creek's [CCA] recommendation regarding sampling design and procedure for final
bond release evaluation starting in 2011." The Division feels the methods used by CCA are
justified and superior to the currently approved method. If SCC wants to change the
sampling design and procedures that are outlined in the approved permit, then the following
items need to be addressed:
a. Remove the sentence stating "...DRMS will be contacted for approval of final
sampling methodology" in the Revegetation Success Criteria section on page 14-22.
b. Amend the text in Tab 14 to reflect the new sampling design and procedures
outlined by CCA.
c. Explain the procedure used to combine all reclaimed areas, being compared to the
Greasewood/Shadscale reference areas, into a single combined unit.
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Mined Land Reclamation Denver • Grand Junction • Durango Active and Inactive Mines